Information We Collect

We may obtain personal information about consumers from various sources, such as:

• Rearden Commerce websites and mobile applications
• Businesses that obtain our products and services for use by their customers or employees (such as financial institutions that use our rewards program platform or employers that use our travel-focused services)
• Social networks through which consumers may access our sites or communicate with us
• Surveys, contests, sweepstakes and other promotions
• Our parent, affiliate or subsidiary companies, service providers, business partners and other third parties

The types of personal information we may obtain include:

• Your contact information (such as name, postal and email address and phone number)
• Contact information of individuals whom you would like us to contact, on whose behalf you request transactions, or who are your emergency contacts
• Information provided to us by businesses that obtain Rearden Commerce products and services for use by their employees or customers
• Information provided to us by social networking or other sites through which you may access our products and services
• Business contact information (such as employer's name and address, job title and business email address and telephone number)
• Government-issued identification information (such as passport number, Alien Registration number and driver's license number)
• Travel information (such as entry visa information, known traveler ID or TSA redress number)
• Travel and dining preferences (such as home airport and train station, seat and meal preferences, travel reward program account number or special travel requirements)
• Usernames and passwords for accounts you may establish on our websites
• Payment and financial details (including payment card number, billing address and bank account number)
• Shipping details
• Demographic information (such as age, date of birth and gender)
• Shopping behavior and preferences, and a record of your purchases and other transactions on our websites
• Other details that you may submit to us or that may be included in the information provided to us by third parties

In addition, when you visit Rearden Commerce websites or use our mobile applications, we may collect certain information by automated means, such as cookies and web beacons. A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "web beacon," also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We also may use third-party website analytics tools (such as Google Analytics and Omniture) that collect information about visitor traffic on our sites. The information we may collect by automated means includes:

• Information about the devices our visitors use to access the Internet (such as the IP address and the type of the device, its operating system type and web browser)
• URLs that refer visitors to our sites, including whether you visited the website directly or were referred from another website or link
• Dates, times and duration of visits to our sites (including whether you are a repeat or first time visitor)
• Information on actions taken on our sites (such as page views and site navigation patterns, the pages, links, banners, icons and other parts of the website on which you click or which you access during your visit)
• Search terms that visitors use to reach Rearden Commerce websites
• Location information, such as the real-time geographic location of the device on which you install our mobile applications

Special Categories of Information

Some of the information you may choose to provide in connection with using Rearden Commerce products and services may be deemed "sensitive" in the country in which you are located. For example, details regarding your air travel meal preferences or wheel chair requirements may be deemed sensitive in the European Union. Your provision of sensitive personal information about you to us is always voluntary. Rearden Commerce does not require you to provide sensitive information as a condition of obtaining our products or services. We use and disclose sensitive information only to provide the products andservices you request and as otherwise required or permitted by law.

How We Use the Information We Collect

We may use the information we obtain about you to:

• Register you on our websites and manage and maintain your accounts on the sites
• Provide products or services you request, such as travel, dining, entertainment, shipping, procurement, expense reimbursement, conference and other arrangements
• Provide Rearden Commerce business customers (such as employers or financial institutions) with the information regarding transactions completed by their employees or customers on the Rearden Commerce platform
• Understand your needs and interests and tailor our products and services to suit your personal interests and the manner in which visitors use our sites, products and services
• Maintain a record of your purchases and other transactions on our sites
• Respond to your questions and comments and provide customer support
• Communicate with you about our products, services, offers, events and promotions, and offer you products and services we believe may be of interest to you
• Enable you to communicate with us through our blogs, social networks and other interactive media
• Manage your participation in our events, sweepstakes and other promotions
• Operate, evaluate and improve our business and the products and services we offer
• Analyze and enhance our marketing communications and strategies (including by identifying when emails sent to you have been received and read)
• Analyze trends and statistics regarding visitors' use of our sites, mobile applications and social media assets, and the transactions visitors conduct on our sites
• Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users
• Enforce our website Terms of Use
• Comply with applicable legal requirements and industry standards and our policies

We may combine the information we collect with publicly available information and information we receive from our parent, affiliate or subsidiary companies, business partners and other third parties. We may use that combined information to enhance and personalize your shopping experience with us, to communicate with you about products, services and events that may be of interest to you, for promotional purposes, and for other purposes described in this Privacy Statement.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

Information We Share

We do not sell or otherwise disclose personal information about you except as described in this Privacy Statement.

Business-Related Disclosures

We may share the information we collect with:

• Our parent, affiliate and subsidiary companies
• Businesses that obtain our products and services for use by their customers or employees
• Other users who, either based on your decision to allow it or based on functionality elected by your employer or other business customer, have been delegated or granted authority to obtain our products or services on your behalf
• Providers whose products and services you may obtain on our sites (such as airlines, restaurants, hotels, travel agencies, car rental agencies, car and taxi services and other merchants)
• Our business and joint marketing partners, service providers who perform services on our behalf, and other third parties

We share the information only for the purposes described in this Privacy Statement, including to communicate with you about products, services, offers, events and promotions that we believe may be of interest to you. Our service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Employers and financial institutions that offer our products and services, merchants, and other third parties with which we share personal information may have their own privacy practices and privacy notices. Rearden Commerce is not responsible for those third parties' privacy practices. As described below, we offer you certain choices regarding how we share information about you.

Required Disclosures

In certain circumstances, we also may disclose information about you without obtaining your consent or offering you an opportunity to opt out. We may do so (i) if we are required to do so or believe to be required to do so by law, regulation or legal process (such as a court order), (ii) in response to a request by law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent or defend against misuse of Rearden Commerce services, violation of our intellectual property rights, breach of any of your or our business customers' obligations to Rearden Commerce, physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.

We also reserve the right to transfer personal information we have about you in the event we sell, merge or transfer all or a portion of our business or assets. Should such a sale, merger or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Statement. Following such a sale, merger or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

Your Choices

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you. Here are the choices we offer.

Use of Rearden Commerce Products and Services

Many of the Rearden Commerce products and services are designed to facilitate and enhance consumers' ability to interact with and obtain products and services from third parties. This business model requires Rearden Commerce to share information about you with various providers (such as airlines, hotels, restaurants, car services and reservation aggregators) and other third parties. These third parties are not our service providers or agents; they may process the personal information we provide to them in accordance with their own privacy practices and privacy notices. You may choose not to provide your personal information to Rearden Commerce or such third parties by refraining from using our products or services. To deactivate your account, you may email us at privacy@reardencommerce.com. If you are using Rearden Commerce products or services that a Rearden Commerce business customer (such as your employer or financial institution) obtained on your behalf, you must contact the relevant business customer to deactivate your account.

Information Provided by Our Business Customers

If your employer, financial institution or another Rearden Commerce business customer provides your personal information to us, you may have certain choices with respect to our use or disclosure of the information. Please contact the relevant Rearden Commerce business customer to learn about and amend your choices.

Marketing Emails

You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in the marketing emails or by adjusting your email preferences using the online account you may establish on our sites.

Web Analytics

You may opt out of the aggregation and analysis of data collected about you on our sites by our web analytics vendors as follows:

• To opt out of aggregation and analysis of data collected by Google Analytics, please click here
• To opt out of aggregation and analysis of data collected by Omniture, please click here

Cookies

Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of our sites' features. In addition, disabling cookies may cancel opt-outs that rely on cookies, such as web analytics or targeted advertising opt-outs.

Your California Privacy Rights

If you are a California resident, you may request that we provide to you (i) a list of the categories of personal information about you that Rearden Commerce has disclosed to third parties for the third parties' direct marketing purposes during the calendar year preceding your request, (ii) the names and addresses of such third parties, and (iii) if the nature of the third parties' business cannot reasonably be determined from their names, examples of the products or services marketed, if known to Rearden Commerce, that are sufficient to give you a reasonable indication of the nature of the third parties' business. To submit your request, please email privacy@reardencommerce.com.

Disclosures to Third Parties

Subject to applicable law in the country where you are located, you may have the right to direct us not to share your personal information with third parties, except (i) with service providers we have retained to perform services on our behalf or (ii) as indicated in the "Required Disclosures" section of this Privacy Statement. To submit your request, please email privacy@reardencommerce.com. In some circumstances, withdrawing your consent to Rearden Commerce's use or disclosure of your personal information will mean that you cannot take advantage of Rearden Commerce products or services.

To update your privacy preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as specified below.

Access and Correction

You may obtain a copy of certain personal information we maintain about you or update or correct inaccuracies in that information by logging into the online account you may establish on our websites.

In addition, if you believe other personal information we maintain about you is inaccurate, you may request that we correct or amend the information by contacting us as indicated in the "How to Contact Us" section of this Privacy Statement. If we deny an access request, we will notify you of the reasons for the denial. If you are using Rearden Commerce products or services that a Rearden Commerce business customer (such your employer or financial institution) obtained on your behalf, you should request such further access to your information from the relevant business customer.

Subject to applicable law, you may have certain additional rights to request access to and receive information about the personal information we maintain about you, update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate.

Links to Other Websites

The Rearden Commerce website may provide links to third-party websites for your convenience and information. If you access those links, you will leave the Rearden Commerce website. Rearden Commerce does not control those sites or their privacy practices, which may differ from Rearden Commerce's practices. We do not endorse or make any representations about third-party websites. The personal information you choose to provide to or that is collected by these third-party websites is not covered by this Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information.

We may also provide social media features on our website that enable you to share Rearden Commerce information with your social networks and to interact with Rearden Commerce on various social media sites. Your use of these features may result in the collection or sharing of information about you. We encourage you to review the privacy policies and settings on the social media sites with which you interact to help you understand those sites' privacy practices.

Data Transfers

When we obtain personal information about you, we may process the information outside of the country in which you are located, including in the United States. The countries in which we process the information may not have the same data protection laws as the country in which you are located. We will protect your information as described in this Privacy Statement.

With respect to personal information that Rearden Commerce receives in the United States from the European Union, Iceland, Liechtenstein, Norway or Switzerland, Rearden Commerce has self-certified that its privacy practices as consistent with the U.S-EU and U.S.-Swiss Safe Harbor privacy principles of Notice, Choice, Onward Transfer, Access, Security, Data Integrity and Enforcement. Please visit our Safe Harbor Privacy Policy for more details.

How We Protect Personal Information

We use commercially reasonable efforts to safeguard the confidentiality of your personal information, including the use of encryption, firewalls and Secure Socket Layers. To help safeguard personal information against loss and unauthorized access, we employ many different security techniques, including, for example, regulating the physical and virtual access to our databases, servers, back-ups, encryption keys or other network and security-related infrastructure components. In addition, we encrypt certain information, such as password and credit card numbers, in storage.

Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.

Data Retention

In the ordinary course of business, Rearden Commerce retains information about you for the purposes described in this Privacy Statement as long as you maintain an active account. We also may retain certain personal information associated with a deactivated account for an additional period (normally at least one year and not longer than 7 years) at your request or to comply with technical, legal, data integrity, fraud prevention and financial reporting requirements.

Career Center

When you visit our Career Center website, we may collect information such as the user name and password you select to establish an account on the site, your employment and education history and other personal information typically collected during the job application process. We use the information to enable you to search and apply for career opportunities at Rearden Commerce, submit your resume for general consideration, email a friend about this the Career Center, and comply with applicable legal requirements and our policies and procedures.

Children's Privacy

Rearden Commerce does not knowingly collect information from children under the age of 13 and does not target its websites to children under 13. If we learn that a user is under 13 years of age, we will promptly delete any personal information that the individual has provided to us. We encourage parents and guardians to take an active role in their children's online activities and interests.

Updates to this Privacy Statement

This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our websites to notify you of any significant changes to our Privacy Statement and indicate at the bottom of the notice when it was most recently updated.

How to Contact Us

If you have any questions or comments about this Privacy Statement, or if you would like us to update the information we have about you or your preferences, please contact us by email at privacy@reardencommerce.com. You also may write to us at:

Rearden Commerce
Attn: Chief Legal Officer – Privacy
Privacy Rights
1051 E. Hillsdale Blvd., Sixth Floor
Foster City, CA 94404